Author
According to the LITP, asylees and foreigners under subsidiary protection shall exercise the right to health care pursuant to the regulations governing health insurance and health care of foreigners in the Republic of Croatia.[1] The costs of health care shall be paid from the State Budget under the item of the Ministry competent for health care.
The Law on Compulsory Health Insurance and Health Care for Foreigners in the Republic of Croatia prescribes that asylees, foreigners under subsidiary protection, foreigners under temporary protection and their family members have the right to health care[2] to the same extent as health insured persons under mandatory health insurance.[3]
According to the Law on Compulsory Health Insurance and Health Care for Foreigners in the Republic of Croatia, the right to health care is provided on the basis of a valid document issued by the Ministry of Interior.[4] The competent police administration or police station is obliged to notify the ministry competent for health that asylum, subsidiary protection or temporary protection was granted to foreigner, at the latest within eight days from the date of execution of the decision granting protection .[5]
This means that there is a difference between the unemployed and employed beneficiaries of international protection. Unemployed beneficiaries of international protection are not insured within the Croatian Health Insurance Fund, but the costs of their health care are covered from the State budget from the position of the ministry responsible for health. In the case of unemployed beneficiaries, health care providers should send invoices, a copy of the residence permit and accompanying medical documentation directly to the Ministry of Health. This category of beneficiaries does not have a health insurance card but prove their status with a residence permit card. Also, they do not have an identity number of the insured person nor are they in the Central Health Information System. When a beneficiary of international protection gets a job and starts paying health insurance contributions, s/he becomes insured. However, unlike Croatian citizens, their family members cannot acquire the right to compulsory health insurance through their insured relative, but costs continue to be covered by the State budget through the Ministry of Health. If a beneficiary of international protection losses employment, he/she ceases to be insured by Croatian Health Insurance Fund.[6] However in practice, healthcare professionals are not sufficiently familiar with the rights of beneficiaries of international protection and the way in which they can exercise their right to health care.
Problems in the health system were reported by NGOs.
For example, AYS reported that although the Law on Compulsory Health Insurance and Health Care for Foreigners provides for the right to access healthcare to the same extent as insured persons, individuals granted international protection cannot obtain the status of an insured person with the Croatian Health Insurance Fund (HZZO), thereby excluding them from the possibility of obtaining supplementary health insurance.[7] In practice, access to primary, secondary, and tertiary healthcare is often limited or difficult. Furthermore, the administration and monitoring of unemployed individuals and children under international protection within the Central Information System of Primary Healthcare in Croatia is extremely limited. Persons who are not insured with the Croatian Health Insurance Fund (HZZO) and therefore do not have a personal insurance identification number (matični broj osiguranika, MBO) cannot have a digital medical record, are not eligible for ePrescription or eAppointment services, and do not have an assigned general practitioner. Instead, they must be registered in the system with each visit. In order to claim reimbursement for the treatment of these patients, healthcare providers and pharmacies are required to submit invoices to the Ministry of Health (through the Croatian Health Insurance Fund) each month. Based on AYS’ experience, medical professionals are generally unfamiliar with the administrative procedures concerning beneficiaries of international protection, or they complain about excessive delays in cost reimbursement, which sometimes results in a refusal to provide the necessary healthcare services.
In 2020, the Ministry of Health provided instructions to relevant health care institutions and pharmacies on the way that medicines should be provided to asylees and persons under subsidiary protection.[8] According to these instructions, the pharmacy delivers an invoice addressed to the Ministry of Health and to the Croatian Health Insurance Fund. A prescription form and a copy of a document issued by the Ministry of the Interior which shows the status of the foreigner to whom the invoice was issued, should be attached to the invoice. The Croatian Health Insurance Fund subsequently submits an invoice for payment to the Ministry of Health after having reviewed the conformity of the medicines prescribed. If it is a medicine that is on the basic list of medicines of the Croatian Health Insurance Fund, the price of the medicine is borne entirely by the Ministry of Health, while in the case of a medicine from the supplementary list, the price is partly borne by the person and partly by the Ministry of Health. If a person is issued a private prescription, the person bears the full cost of the medicine.
The Ombudswoman’s report for 2024 emphasised that although the LITP states that persons under international protection have the right to health care in accordance with the Law on Compulsory Health Insurance and Health Care for Foreigners, there are difficulties in the implementation of these laws as reported above. Furthermore, the Ombudswoman notes that, as a consequence, general practitioners often refuse to accept them, and it is particularly concerning that pediatricians are refusing to accept children. Additionally, under the Law on Voluntary Health Insurance, only persons who have established their status as insured persons in the mandatory health insurance system may have voluntary health insurance. As a result, costs of co-payments and additional services (dental care, orthopedic aids, medicines from the B list, etc.) must be covered by the individuals themselves, without the possibility of contracting supplementary insurance. Only upon employment do they become mandatory insured persons of the Croatian Health Insurance Fund, at which point they are entered into the system and receive a corresponding unique identification number. However, children beneficiaries of international protection are not able to obtain this right at all, which is particularly concerning given the lower financial capacity of unemployed persons or families under international protection, who cannot afford more complex forms of treatment that would otherwise be covered by supplementary health insurance. Moreover, persons who are not insured by the Croatian Health Insurance Fund and do not have their own unique identification number cannot have a digital medical record, cannot use services such as ePrescription and eReferral, and do not have a chosen physician. Instead, they must be newly registered in the system during each visit, and in order to reimburse the costs of treating such patients, doctors/pharmacies are required to send invoices to the Ministry of Health every month—a process many doctors are not even aware of. Regarding the recommendation to the Ministry of Health to adopt a regulation that would govern access to healthcare services and clearly define how services for persons under international protection are to be provided and reimbursed, it is positive that a working group has been appointed to draft the regulation. The working group includes representatives of the Ministry of Health, Ministry of the Interior, Ministry of Labour, Pension System, Family and Social Policy, and Croatian Health Insurance Fund. However, as highlighted by the Ombudswoman, it is discouraging that the group was established back in 2022 and that the regulation has still not been adopted, while the issues remain unresolved.[9]
In the course of 2024, AYS provided information on the scope of the right to health care to beneficiaries of international protection, but also assisted them with enrolment procedures or when persons undertook medical examinations. AYS highlighted that the non-recognition of the right to health care for beneficiaries of international protection remains a shortcoming.[10]
Centre for Peace Studies (CPS published a Guide for citizens of third countries on access to healthcare in Croatia.[11] The guide contains information about the basic terms that people face when accessing the health system and when communicating with doctors and other health service providers in Croatia. The guide also contains instructions on how to find a primary care doctor and other useful instructions for accessing healthcare in Croatia. The guide is availbe in Croatian,[12] Arabic,[13] English,[14] French,[15] Hindu,[16] Nepali,[17], Turkish, and Ukrainian.[18]
In addition to the Guide, CPS has created video materials on the e-Citizens Portal,[19] and Finding General Practitioners and Gynaecologists for foreigners in the Republic of Croatia.[20]
[1] Article 69(1)-(2) LITP.
[2] Article 17 Law on Compulsory Health Insurance and Health Care for Foreigners in the Republic of Croatia.
[3] Article 21(1) Law on Compulsory Health Insurance and Health Care for Foreigners in the Republic of Croatia.
[4] Article 21(2) Law on Compulsory Health Insurance and Health Care for Foreigners in the Republic of Croatia.
[5] Article 21(3) Law on Compulsory Health Insurance and Health Care for Foreigners in the Republic of Croatia.
[6] Croatian Association of Social Workers: Handbook- The role of social welfare in the process of integration of persons with international protection, available at: https://bit.ly/3uti9M5.
[7] Information provided by AYS, 15 January 2025.
[8] Ministry of Health: Letter from the Ministry of Health to Croatian Health Insurance Fund, 15 July 2020, available at: https://bit.ly/3tD9kh1.
[9] Ombudswoman, Report of the Ombudswoman for 2024, available in Croatian at: https://www.ombudsman.hr/wp-content/uploads/2025/05/Izvjesce-pucke-pravobraniteljice-za-2024.-godinu-2.pdf.
[10] Information provided by Are you Syrious, 15 January 2025.
[11] Centre for Peace Studies: Guide for citizens of third countries on access to healthcare in Croatia, available at: https://bit.ly/4cqVq6G.
[12] https://www.cms.hr/publikacija/vodic-za-drzavljane-trecih-zemalja-pristup-zdravstvu-u-hrvatskoj-hrv/.
[13] https://www.cms.hr/publikacija/arab/.
[14] https://www.cms.hr/publikacija/guide-for-third-country-nationals-access-to-health-care-in-croatia-eng/.
[15] https://www.cms.hr/publikacija/guide-pour-les-ressortissants-de-pays-tiers-acces-aux-soins-de-sante-en-croatie-fra/.
[16] https://www.cms.hr/publikacija/hindu/.
[17] https://www.cms.hr/publikacija/nepali/.
[18] https://www.cms.hr/publikacija/ukr/.
[19] e-Citizens is a central point for all public sector information and services in Croatia.
[20] Video materials available at: https://bit.ly/3xsDABh.